FAQs on Recent Updates to FCC Covered List Regarding Routers Produced in Foreign Countries

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What is the FCC's Covered List?  What restrictions does it impose on "covered" equipment on the List?

• The FCC’s Covered List is a list of communications equipment and services that are deemed to pose an unacceptable risk to the national security of the U.S. or the safety and security of U.S. persons.
• Under the Secure Networks Act, the FCC can update the Covered List only after the direction of a qualifying national security authority. In other words, the Commission cannot update this list on its own and is required to implement determinations that are made by our national security agency experts.
• Equipment on the Covered List (“covered equipment”) is prohibited from getting FCC equipment authorization.  Most electronic devices require FCC equipment authorization prior to importation, marketing, or sale in the U.S. Covered equipment is banned from receiving new equipment authorizations, preventing new devices from entering the U.S. market.
  • Additionally, the Cybersecurity and Infrastructure Security Agency encourages organizations to use the Covered List for risk management analysis in their regulatory compliance efforts.
• New models of devices on the Covered List are prohibited from receiving FCC authorization and are therefore prohibited from being imported or sold in the U.S.  Being added to the Covered List today does not prohibit the import, sale, or use of any existing device models the FCC previously authorized.
• The Covered List does not restrict the continued use by consumers of previously-purchased devices.  Consumers can continue to use the devices they lawfully purchased. 

Why did the FCC add routers produced in foreign countries to the Covered List on March 23, 2026? 

• The FCC updated the Covered List following a thorough review by a White House-convened Executive Branch interagency body with appropriate national security expertise, which jointly and severally made a specific determination that routers produced in any foreign country pose “unacceptable risks to the national security of the United States and to the safety and security of U.S. persons” and should be included on the FCC’s Covered List.
• This determination also allowed for exemptions if the Department of War (DoW) or the Department of Homeland Security (DHS) transmits a specific determination to the FCC that a given router, or class of routers, does not pose such risks.
• Therefore, the FCC updated its Covered List to include “Routers produced in a foreign country, except routers which have been granted a Conditional Approval by DoW or DHS.”
• In their determination, national security agencies referenced, among other things, concerns that routers produced in foreign countries could introduce a supply chain vulnerability that could disrupt the U.S. economy, critical infrastructure, and national defense and establish a severe cybersecurity risk that could be leveraged to immediately and severely disrupt U.S. critical infrastructure and directly harm U.S. persons.  

What is the impact of the FCC adding routers produced in a foreign country to the Covered List?  

• All “new” models of foreign-produced routers will not be eligible to receive FCC equipment authorization (unless they are granted Conditional Approvals by DoW or DHS) and therefore may not be imported or sold in the U.S.
• Foreign-produced routers that have previously received FCC authorization (as shown by the FCC ID on the device) may continue to be imported, sold, and used in the U.S.

Do consumers currently using covered routers in small and home offices need to do anything?

• Consumers currently using covered routers in small and home offices do not need to do anything.
• The Covered List does not restrict the continued use by consumers of previously-purchased devices.  
• Consumers will continue to be able to purchase previously authorized routers.

Are there any restrictions on consumers' ability to use covered routers?

• No.

Are any foreign-produced routers exempt from the Covered List?

• Yes, the National Security Determination stated that foreign-produced routers pose unacceptable risk to the national security of the United States and to the safety and security of U.S. persons “unless Department of War (DoW) or the Department of Homeland Security (DHS) transmits to the FCC a specific determination that a given router or class of routers do not pose such risks.”  The National Security Determination also included guidance to apply for “Conditional Approvals” from DoW and DHS.  DoW and DHS will evaluate individual requests for specific determinations that certain routers do not pose “unacceptable risks.”
• Therefore, the FCC updated the Covered List to include “routers produced in a foreign country, regardless of the nationality of the producer, except for routers that have been granted a Conditional Approval by DoW or DHS.”  
   

How can I receive a Conditional Approval for my foreign-produced router?

• Entities can apply for “Conditional Approvals” by submitting an email with the information in the guidance to conditional-approvals@fcc.gov.  The information will be forwarded to DoW and DHS for their evaluation.  The FCC will update the Covered List based on Conditional Approvals it receives from DoW or DHS and publish the relevant information on the Covered List website.  

How are routers defined?

• The FCC followed the definitions in the National Security Determination.  
• “Routers” is defined by National Institute of Standards and Technology’s Internal Report 8425A to mean consumer-grade networking devices that are primarily intended for residential use and can be installed by the customer.  Routers forward data packets, most commonly Internet Protocol (IP) packets, between networked systems. 
   

What constitutes “produced in a foreign country”? Is there a content threshold?

• The National Security Determination states that “[p]roduction generally includes any major stage of the process through which the device is made including manufacturing, assembly, design, and development.”
• In the equipment authorization process, applicants have to self-certify that any RF device is not “covered equipment.”  Going forward, this includes self-certification that the RF device is not a router “produced in a foreign country.” 
• Applicants seeking equipment authorization for any router will bear responsibility for certifying, in good faith, that any such router was not “produced in a foreign country.”

Does the nationality of the entity producing the router affect its status as either “covered” or not-covered?

• The nationality of the entity or entities producing routers is not relevant to whether such routers are considered to be “produced in a foreign country.”  

If a router is designed in the U.S., but manufactured abroad, is it “covered”?  What about if a router is designed abroad, but manufactured in the U.S.? 

• Both types of routers are “covered.”  The National Security Determination states that “Production generally includes any major stage of the process through which the device is made, including manufacturing, assembly, design, and development.”  
• Producers of routers with these processes made abroad should apply for Conditional Approval.
   

Can I import a new model of a foreign-produced router solely for product development purposes? 

• Consistent with FCC regulations, 47 CFR § 2.1204(a)(3), entities may import small batches of unauthorized devices solely for product development purposes, provided such devices are not marketed or sold.

Does this action affect the Supplier’s Declaration of Conformity (SDoC) equipment authorization process for routers produced abroad? 

• All newly-covered devices are prohibited from receiving any FCC equipment authorization, including via the streamlined SDoC equipment authorization process. 
• Entities “identified on the Covered List” are generally prohibited from obtaining equipment authorizations through the SDoC process for even their non-covered devices.  47 CFR §§ 2.906(d); 2.907(c). 
• However, as noted in the Public Notice announcing the routers Covered List update, entities that produce routers in a foreign country are not considered “identified on the Covered List.”  Such entities will therefore still be able to take advantage of the SDoC process for their non-covered devices.  

If someone buys a router outside the US, can they use it in the U.S.?

• There is no restriction on the use of “covered” routers that have already received FCC equipment authorization and display an FCC ID.
• For “covered” routers that have not received FCC equipment authorization, the general answer is “no”.  
   

Is a router produced in the United States containing foreign-produced components now “covered equipment” and prohibited from FCC equipment authorization?

• Non-“covered” devices do not become “covered” simply because they contain a “covered” component part, unless the “covered” component part is a modular transmitter under the FCC’s rules.  47 CFR §§ 2.903(b), 15.212. 
• Therefore, a router produced in the United States is not considered “covered” equipment solely because it contains one or more foreign-made components.

Do applicants need to have documentation or evidence to demonstrate that a component was not produced in a foreign country?

• To get equipment certification for routers, applicants will need to certify that the device is not covered equipment, i.e. is not produced in a foreign country. 
• Applicants will need to be able to have sufficient evidence that the routers were not produced in a foreign country to make this certification, but there is no specific documentation or evidence required. 

Does this affect government purchases or use of routers?

• No, the Covered List does not restrict the import or sale of routers for the exclusive use by the federal government.

Can routers on the Covered List get basic software and firmware edits?

• Yes, pursuant to a waiver of its rules, these devices can continue to receive basic software and firmware updates to maintain usability.